As more private investment funds will be pulled under the regulatory umbrella of the Investment Advisers Act,they will need to focus on the limitation on performance fees. Section 205(a)(1) of the Advisers Act generally prohibits any investment adviser, unless exempt from registration pursuant to Section 203(b) of the Advisers Act, from entering into, extending, renewing, [...]
Archive | July, 2010
A Closer Look at the new SEC Rule 206(4)-5 on Pay to Play
Over the weekend, the Securities and Exchange Commission released the full text of Rule 206(4)-5 in Release No. IA-3043. I made few notes during the broadcast of the open meeting, but there were lots of unanswered questions. Rule 206(4)-5 is only 12 pages long, but Release IA-3043 also includes another 190 pages of commentary and [...]
The Changing Standard for an Accredited Investor
As financial reform has made its way through Congress there have been several proposed changes to the standard of what it takes to be an accredited investor. In 1982, the SEC prescribed the standard in Rule 501 of Regulation D: 5. Any natural person whose individual net worth, or joint net worth with that person’s [...]
Fourth of July and Compliance
With the Fourth of July on Sunday, most businesses are closed on July 5th. (We hate to waste a good holiday.) What better way to celebrate the independence of the United States than by taking the day off from work and watching stuff blow up. In colonial times, official proclamations were read from the Old [...]
Compliance Bits and Pieces – July 2
Early this week, some people expected fireworks to come from the Free Enterprise v. PCAOB decision. Instead, we got cheap package of sparklers. Fun for a few minutes, but unlikely to leave much of a lasting impression. Here are some interesting compliance-related stories from the past week. SEC Statement on Supreme Court’s Decision in FEF [...]
Cheap Sunglasses and Compliance
Can cheap sunglasses affect your ethical behavior? An important part of a compliance program is monitoring and improving the ethical behavior of your workforce. I’m always intrigued by ethics experiments. Francesca Gino of Chapel Hill, Michael Norton of Harvard Business School, and Dan Ariely of Duke tested the effect of wearing knock-off designer sunglasses. They [...]
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